When Is an
EPC Not Required?

The main EPC exemptions in UK law

Most UK properties need an EPC for sale, rent or new build. The exemptions cover specific categories where the rules would not work properly or would impose disproportionate burden. Each exemption is narrow plus must be properly assessed.

Exemption 1: Listed buildings (character impact test). Listed buildings are exempt from EPC requirements only when compliance with minimum energy performance requirements would unacceptably alter character or appearance. This is a property-by-property test, not based on listing alone. Many Grade II listed homes can have loft insulation plus internal upgrades without character damage plus do still need EPCs. Local authority conservation officers can advise on the character impact test.

Exemption 2: Places of worship plus religious buildings. Buildings used for religious activities are exempt. Includes churches, mosques, synagogues, temples plus other religious gathering spaces. Multi-use buildings with religious plus secular functions may need partial EPCs covering the secular portions only.

Exemption 3: Temporary buildings (under 2 years). Buildings designed plus used for less than 2 years are exempt. Includes site huts, marquees with planning consent for under 2 years plus temporary exhibition structures. Use must be intended as temporary at the time of construction.

Exemption 4: Industrial sites, workshops plus non-residential agricultural buildings with low energy demand. Includes:

• Industrial warehouses with no fixed heating system.
• Workshops with no occupant comfort heating.
• Storage units plus self-storage facilities.
• Cold stores plus chilled storage (cooling for goods not occupants).
• Agricultural barns, sheds plus stables.
• Open-sided structures plus canopies.
• Garages plus motor vehicle storage.

Mixed-use buildings with heated office sections plus unheated warehouse sections typically need partial EPCs covering the heated portion only.

Exemption 5: Standalone buildings under 50 square metres. Buildings with total useful floor space less than 50 square metres are exempt. Useful floor space excludes utility cupboards plus mezzanine areas with low headroom. Most garden offices, summer houses plus small annexes fall under this exemption. Note that the exemption only applies to truly standalone buildings, not extensions to existing buildings.

Exemption 6: Buildings due for demolition. Properties for which the seller has applied for relevant planning consent or demolition consent are exempt. The intention to demolish must be documented. Sellers must be able to evidence the planning application or demolition notice if challenged.

Exemption 7: Holiday lets used for less than 4 months per year. Holiday lets used for less than 4 months total in any year are exempt from the rental EPC requirement. The 4-month threshold is cumulative across the year, not consecutive. Holiday lets used for more than 4 months per year are treated as standard rental properties plus need EPCs rated E or above (rising to C from October 2030).

How to confirm an exemption. Each exemption is narrow plus owners should:

• Document the exemption case in writing. Photographs, floor plans plus written advice from professionals where applicable.
• Keep records on file. Useful for sales, letting plus enforcement queries.
• Consult professionals for borderline cases. Conservation officers (listed buildings), commercial Energy Assessors (industrial sites) or solicitors (legal interpretation).
• Confirm with local Trading Standards or Building Control if uncertain.

What exemption does NOT mean. Exemption from EPC requirement does not exempt the property from:

• Building Regulations Part L energy performance requirements at construction or major renovation.
• MEES Regulations rental rules (separate exemption process via PRS Exemptions Register if applicable).
• Other property safety plus condition regulations.
• Listed Building Consent requirements for any physical alterations.

If your property does need an EPC after all. If the exemption assessment shows the property is not exempt, commission an EPC from an accredited Domestic Energy Assessor. Cost £60 to £150 for a typical UK home. Process takes 3 to 7 days from booking to receiving the issued certificate.

EPC exemptions are narrow but useful when they apply. Our full EPC Ratings hub covers Energy Performance Certificates plus MEES regulations across UK homes plus rental properties.